BlackBerry Limited v. The King, 2024 TCC 123 -- summary under Paragraph 95(3)(b)
s. 95(3)(b) exclusion applied where inbound R&D services from US subsidiaries were inextricably linked with product sales
The taxpayer (“BlackBerry”), which in its 2010 taxation year generated $8 billion in sales of smartphones to BlackBerry US, which on-sold...
Words and Phrases
in connection with| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(b) - Subparagraph 95(2)(b)(i) | s. 95(2)(b)(i) was inapplicable where no net inbound services were provided | 221 |
| Tax Topics - Income Tax Act - Section 95 - Subsection 95(3) - Paragraph 95(3)(d) | s. 95(3)(d) exclusion applied where inbound R&D services from US subsidiaries were inextricably linked with offshore manufacturing | 224 |
| Tax Topics - Income Tax Act - Section 91 - Subsection 91(4) | US tax credit for R&D work of US affiliates was allocated to the US consolidated group (earning business income) rather than to those particular affiliates (allegedly earning FAPI) | 170 |